Technically it's a valid solution. The key word is "may". A responder can wait as long as it wishes for the inter-slot timeout. Realistically though, no controller would generate packets like that because it would fail with many responders.
RDM has pretty tight timing restrictions. A device (controller or responder) which has scheduling delays in the 10ms range is unlikely to work reliably with RDM. You really need sub-millisecond level control to build an RDM device.
Typically, that means the USB UARTs from companies like FTDI and SiLabs won't work for RDM on their own. You need a microcontroller or PLD to generate more accurate timing.
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